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Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Subsection 32.1(1)
Given the potentially significant differences in both the amount and timing of the reimbursement payment as compared to the actual contributions made by Parentco … the reimbursement payments are not equivalent to Parentco’s contributions to the EBP, and thus cannot be considered to be a proxy for those contributions. ...
Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Subsection 152(4)
If it is determined that the TPRs were due to an error … the TPRs for all of the taxation years could be accepted. ...
Conference summary
3 December 2019 CTF Roundtable Q. 16, 2019-0824471C6 - Eligible Dividend Designation -- summary under Subsection 89(14)
After responding negatively, CRA stated:... 2009-0347491C6 … provided examples of acceptable notifications of the payment of an eligible dividend from a corporation other than a public corporation to the dividend recipient. ...
Conference summary
11 October 2019 APFF Roundtable Q. 3, 2019-0812621C6 F - Changement d’usage-impact sur l’exemption pour résidence principale -- summary under Paragraph (c)
The taxpayer will therefore have to file two worksheets and two T2091 forms … if the taxpayer wishes to designate Unit 2 and Unit 3 as his principal residence for the applicable years. ...
Conference summary
11 October 2019 APFF Roundtable Q. 10, 2019-0812691C6 - Consolidated safe income -- summary under Paragraph 55(2.1)(c)
Should the safe income attributable to the shares of Holdco be reduced by negative safe income given that the latter does not reduce the accrued capital gain in the shares – or is such amount $900,000? ...
Technical Interpretation - External summary
9 April 2020 External T.I. 2014-0527261E5 F - Beneficial ownership discretionary power of trustees -- summary under Paragraph 107.4(1)(i)
Consequently, the requirement in paragraph 107.4(1)(i) would be satisfied …. ...
Technical Interpretation - External summary
12 June 2020 External T.I. 2018-0788161E5 F - Adjusted stub period accrual amount -- summary under Element B
Consequently … no limited partnership loss can be deducted by Opco in computing the ASPA so as to reduce the amount to be added to its income under subsection 34.2(1). ...
Conference summary
8 July 2020 CALU Roundtable Q. 5, 2020-0842191C6 - Jointly owned policies - 70(5.3) -- summary under Subsection 70(5.3)
. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...
Technical Interpretation - External summary
13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits -- summary under Paragraph (a)
CRA noted that the FMV of the property in the RRSP normally would have been included in the deceased annuitant’s income under s. 146(8.8) but here, there was no inclusion of such amount in the final return because the executor was unaware of the RRSP – and that return now was statute-barred. ...
Conference summary
26 November 2020 STEP Roundtable Q. 2, 2020-0840001C6 - Subsection 104(13.4) and LCBs -- summary under Subsection 161(1)
CRA indicated that the loss carryback requested on the form T3A filed with the 2 nd return will not be processed concurrently with the T3 return for 1 st taxation year, as the loss must first be recognized by CRA before it can be applied to the earlier taxation year – so that the initial notice of assessment for the 1 st taxation year would not reflect the carryback, and would show interest owing where the computed balance of tax owing was not paid on or before March 31. ...